Privacy Policy

SECTION 1 - Introduction

Who are we?

We are Relive B.V. (Relive). Our address is Postbus 21719, 3001AS Rotterdam, the Netherlands. We are registered with the Chamber of Commerce (Kamer van Koophandel) under number 67325718.

What do we do?

We offer you access to our application and web application (together: the App) that enables you to relive your outdoor activities, explore new routes, meet people in communities and share your activities on our App.

What are you reading here?

This is our Privacy Policy, explaining which data we collect and how we use it (the Privacy Policy). In addition, you can read how we store and protect your data and which privacy rights you can invoke. When we refer to you in this Privacy Policy, we mean you as a user of our App. This Privacy Policy applies to our website www.relive.cc (the Website), our App and the services or products we provide (the Services).

We may modify this Privacy Policy. We shall notify registered users in case of a substantial modification via e-mail. If you are not a registered user, we advise you to consult the Website, App and this Privacy Policy regularly.

SECTION 2 - Data Collection

We may receive your data in a few different ways. We receive data you directly share with us, for example when you create an account or when you upload certain activities. Sometimes we also collect data ourselves, for example on how you use our Services. Finally, we may also receive data when you use third-party service providers that we facilitate via our App. Below we have explained in more detail which data we collect, how we use it and our legal motivation.

SECTION 2.1 - Data collected by Relive

We shall only use your data for the following purposes or for compatible purposes. By doing so, we will not use your data in an unexpected manner.

Account data

In order to start using Relive, you need to sign up and create an account. Your account details can be changed or supplemented at any time in the settings section in the App. We use account data so that you can log in to Relive and we can personalize our Services. We also use your account data to communicate with you about our Services, for example when you’ve forgotten your password or when your video is ready. That way we can help you use our Services and inform you about relevant updates. You can manage your contact settings on your profile.

  • first and/or last name
  • username
  • email address
  • bio (optional)
  • profile picture (optional)

Payment data

You can upgrade your personal account to use Relive Plus, our premium service. To bring you Relive Plus, we process payment data to facilitate payments, send invoices and update our financial administration, being:

  • payment details: contact- and credit card details
  • overview of the purchases of our Services
  • Invoices

We don’t process any payment information at all if you pay via Apple or Google.

Location data

In order to provide Relive’s core Services, it is necessary for us to track the location of your device while you are using Relive. We collect and process the location of your device when you sign up for and use our Services. We do not track the location of your device when you are not using the App. If you want to stop device location tracking, you can do so at any time by adjusting your device settings.

Content data

We gather information from the photos, posts, comments, ratings, reviews, and other content you share on the Services, including when you participate in challenges or create routes.

Technical information and log files

We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.

The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.

Activity data

We collect the following activity data:

  • your tracked route (GPS-points);
  • media data: photos and videos;
  • additional information you may add to the activity, such as the title you give to an activity or tagging of a photo.

We process your activity data in order to provide our Services to you:

  1. We can record your activities and analyze your performances, in order to provide you with the relevant feedback;
  2. You can interact with other users on the App. This allows you to participate in challenges, follow other users and communicate with each other;
  3. We can manage your training. For example, to set goals and use your training dashboard;
  4. Discover new places to go. For example, to discover routes where you can run or ride or to identify points of interest;
  5. To visualize your activities in new ways. For example, by creating personal heatmaps or personal videos.
  6. To enrich the content in our App. For example, we can add publicly available photos of users to routes, unless you have opted out for this functionality.

Data from third party providers

If you sign up via third parties (such as Google or Apple), we will receive profile data to create a Relive account. If you cancel the process of signing up, we cannot provide you with our Services and we will not save the data you entered.

We also collaborate with third party applications like Garmin and Polar Flow (Trackers). You should exercise caution when sharing information through Trackers and you should carefully review the privacy practices of these third parties. By connecting your account with a Tracker, you give Relive permission to transfer and use data, provided by the Trackers, for the purposes of making a personal video or route. You can always disconnect these Trackers via your settings, upon which we will stop collecting data related to your activities and delete the imported data in accordance with the our retention periods.

  • profile information on the third party service in order to fill and update your Relive profile;
  • activity data: note that when you use Relive via a Tracker, the activity data may include health data such as your heart rate. We are not able to delete this data as it is often embedded in the received activity data.

Additionally, we use Snowplow to collect user experience data on the Website. This enables us to conduct optimisations on the Website. We collect the following data via Snowplow:

  • Timestamps
  • Details about the page visit
  • User agent details
  • Browser settings
  • Session identifier
  • Session index

The detailed information is stored for 30 days. We also collect pseudonymised IP information and a visitor identifier based on a custom cookie which is valid for 30 days. This data is processed on the basis of legitimate interest (improving the website experience). And none of the data is shared across domains.

We also use Unbounce as a third-party service on our landing pages (e.g. www.relive.cc) to enhance our website's functionality and improve user experience. Unbounce allows us to create, manage, and analyse landing pages to better serve our visitors. This service may collect and store data, such as your IP address, device information, and interaction with our landing pages. We utilise this data to optimize our content and marketing efforts. Unbounce adheres to strict data protection standards, and any data shared with them is managed in accordance with our privacy policy and relevant data protection laws. For more information on data protection and security at Unbounce, click here.

Data for marketing and promotional reasons

We use the following data to offer and promote our Services, activities and events on Relive and other commercial products or Services.

  • name
  • email address
  • interests
  • purchase overview

SECTION 2.2 - Legal background

We consider Personal Data to be any data relating to an identified or identifiable person, in conformity with the General Data Protection Regulation (the GDPR). As an identified or identifiable person to whom the Personal Data relates, you are the Data Subject in this context. We process your Personal Data in accordance with the GDPR and all other relevant legislation and regulations in the field of protection of Personal Data, like the Dutch Telecommunications Act (Telecommunicatiewet) regarding the use of cookies (the Relevant Legislation). We are allowed to process your Personal Data, because we comply with the Relevant Legislation. The processing of your Personal Data is based on the following grounds of the GDPR:

Performance of the contract

We process (part of) your account data, payment data, location data and activity data in order to fulfill our agreement with you. We need to process this Personal Data so we can provide our core Services to you:

  • Create an account and give you access to the Services
  • Record your activities
  • Help you analyze your performance. For example, to compare your past efforts and analyze your training
  • Help you manage your training. For example, to set goals and use your training dashboard
  • Process your Relive membership
  • Responding to your support requests and comments.

Legitimate interest

We process (part of) your location data, public activity data and data for marketing purposes based on our legitimate interest. For the legal basis of legitimate interest, an assessment was made on behalf of our interests on the one hand and your interests, fundamental rights and freedoms as the Data Subject on the other. This balancing test assesses whether your interests should override ours. Processing your Personal Data on the legitimate interest ground is important to us, because it enables us to offer you a better App and Services. More specifically, we can:

  • Support community powered features: enable you to find new ways to interact through our Services. For example, we allow users to explore each other’s routes or allow users to participate in challenges.
  • Convert your data in aggregate form to enhance our Services: identify points of interest or popular areas, customize the Service (e.g. suggesting routes, challenges, etc.) and create global heat maps.
  • Customize the Services: we may suggest routes or challenges that may interest you or new features you may want to try.
  • Promote the Services: through Service-related email and product-related marketing campaigns to make you aware of our Services.

You are by default opted-in to the processing of your activity data. However, we offer the possibility to opt-out of the processing at any time through our settings. The conclusion of this assessment is that in our opinion Relive may use ‘legitimate interest’ for the processing of the specified Personal Data. However, this assessment is subjective. Do you disagree with the processing of your Personal Data based on our legitimate interest? Then you can always object to this. We will then reassess the processing of your Personal Data including your objections and presented interests and inform you of its outcome and continuance of the processing on this basis.

Consent

We request your consent to process your data for certain purposes and you are entitled to withdraw your consent at any time. We ask your consent:

  • For collecting and processing data from Trackers which you connect to your Relive account, including possible health information such as your heart rate
  • To access photos, location and contact information through your device-based settings, after you have enabled the settings

If we process the data, you provide us subject to your consent, your consent is limited to the specific content of such a consent. You have the right to withdraw your consent at any time through our settings.

Legal obligations or to establish, exercise or defend legal claims

We process data if we are required to do so by law, for example in the context of a legally valid and binding legal action by a law enforcement agency to obtain certain data. In addition, we may be required to process data to establish, bring or defend civil or criminal claims in connection with actual or potential litigation, for example to protect Relive’s services, our property or other legal rights, including those of our members or partners.

SECTION 3 - Data Protection

We do our utmost to protect your Personal Data from being lost, destroyed, abused, altered or spread by unauthorized parties. This way we ensure that only the necessary persons have access to your Personal Data. We ensure this by taking the following (security) measures:

  • Encryption of digital files containing Personal Data;
  • Secure network connections with Secure Socket Layer (SSL), or a comparable technology;
  • The access to the Personal Data is strictly limited to the employees on a ‘need to know’ basis;
  • Access to the Personal Data is secured with a two-factor authentication (2FA);
  • We back-up data regularly to ensure we can provide a reliable service. We cannot ensure the deletion of your Personal Data from these back-ups. In the event that we need to recover a backup, all Personal Data that is restored with that action will be deleted according to our data retention policy as soon as possible;
  • Non-disclosure agreements (NDA’s).

We constantly check our security measures for effectiveness and, if necessary, adjust our process. This way, your Personal Data are always protected and accessible in the event of a (technical or physical) failure.

SECTION 4 - Data Storage

We maintain your Personal Data for as long as necessary to provide our Services to you. We delete your Personal Data after we no longer need them:

  • We will retain your payment data for a period of 7 years, to meet our financial and tax requirements and obligations;
  • We will retain your account data for no longer than necessary to provide the Services, or until your account is deleted. We automatically delete your account data when your account has been inactive for 48 months.

If you want to view, export or delete your Personal Data, please send us an e-mail. We will try to act upon your request within 30 days. After you request deletion of your account, we will permanently and irreversibly delete your Personal Data from our systems, including back-ups. We may ask for additional Personal Data when deletion requests are made, to comply with the law and take other legally permitted actions.

Please note that content you have shared with other users, for example photos, may remain visible even after you delete your account. We cannot delete the Personal Data you publicly shared, such as photos or videos you shared via social media. In addition, your public profile may appear in search engine results until the search engine refreshes its cache.

Relive also provides you with the option to delete individual activities you have posted, without deleting your account. After deletion, the activities may remain on our systems until you delete your account.

SECTION 5 - Data Sharing

Processors

We may share your Personal Data with third parties that provide Services to Relive. These are Processors within the meaning of the Relevant Legislation. Processors are given access only to the Personal Data they need to perform these limited tasks on our behalf and are obligated to protect and safeguard your Personal Data. In addition, we agree with Processors that they will handle your Personal Data with care. We might share the following Personal Data with Processors:

  • Payment providers – your payment data for the execution of payment services;
  • Google Analytics – your behaviour on our Website and App, to help us improve our Services;
  • Wufoo – your email address, to provide you with contact forms.
  • Cloud and hosting providers - relevant data for the hosting and storage of our App;

Third parties

Relives provides an Application Programming Interface (API) to enable easy Personal Data sharing between Relive and Trackers of your choice. Relive will only share your Personal Data with Trackers, if you have given your explicit consent by authorizing Tracker to do so. When you authorize Trackers to access your Personal Data stored on Relive on your behalf, the use of your Personal Data by the Tracker is governed by the relationship between you and the Tracker (e.g.: their privacy policy). Relive is not responsible for these Trackers or how they process your Personal Data.

Other

If we have a legal obligation to share your Personal Data, we will do so. This is the case, for example, if a public authority legally requires us to share your Personal Data.

Transfer

We shall process your Personal Data within the European Economic Area (EEA) to the extent possible. We will only process your Personal Data outside the EEA if that country offers an appropriate level of protection for your Personal Data. For the transfer of Personal Data we use, where appropriate, standard contractual clauses (SCC) approved by the European Commission. We shall never transfer your Personal Data to countries or parties other than those mentioned above without your consent.

SECTION 6 - Privacy Settings

We offer a variety of tools to manage the sharing of your information and encourage you to customize the settings to your desired experience.

Profile privacy

When you sign up for an account on Relive, you can choose in your settings between Everyone and Followers. If you set your account to Everyone, your Personal Data will be visible to everyone using our App and on the web. If you set your account to Followers, your Personal Data will only be visible to your approved followers. When you join Relive, your account is set to Everyone by default. You can change this at any time in the privacy settings. Some parts of your profile, such as your (user)name and profile picture, will always be publicly available to other users.

Activity privacy

An activity can be Public or Private. When you join Relive, your activities are in default set to Public, whether you set your account to Everyone or Followers. Public means that your activities can be found in the App in various places, depending on your profile settings. You can also set any activity to Private. An activity set to private will not be used for any purpose.

Aggregated data use

We may aggregate the information you and others make available to Relive to enhance the service. For example – we may aggregate your activity data to identify popular routes or points of interest to share with the community. When you join Relive your account is set to allow aggregated data use by default. You can change this at any time in the privacy settings.

We take special measures to minimize the (possible) impact on your privacy when processing data for aggregated use. The most important measures we take are anonymization and aggregation of data. Anonymization means that we separate the identifying factors from your Personal Data, which enables us to only use the non-personal data. Aggregation means we combine your (non-personal) data with data of other users and then summarize it. By combining and summarizing the data, we reduce the risk that the data we display in our App, such as a popular route, can be linked to you as an individual user.

Public photos on routes

We may show photos that you have chosen to upload to Relive to other users when they are viewing Routes in our app. We do this by default for profiles set to Everyone who have activities set to Public. You can opt out of this at any time in the privacy settings.

Privacy zone

We offer privacy zones. You can notify us of important locations you want to hide, such as your home or work address, by enabling a privacy zone in your settings. Privacy zones apply going forward but not retroactively. Any part of your activity that is covered by a privacy zone, including photos and videos, will be private and therefore not visible to other users. The part of your activity covered by a privacy zone will only be visible to you, and the relevant data will still contribute to statistics and challenges. Finally, we will not use the part of your activity covered by a privacy zone for our aggregate data use.

Trackers may also allow you to create privacy zones. Please note that Trackers might not always accurately share this data with us, but rather give us the unfiltered data. If you see your route within your privacy zone, we advise you to contact the relevant Tracker to stop sharing locations within your privacy zone.

SECTION 7 - Privacy Rights

You have the following rights:

  • Right of access - you can request access to your Personal Data.
  • Right to rectification - you can request us to correct, limit or delete your Personal Data. You can also edit your profile, delete content you have posted, make individual activities invisible or delete your account via the App.
  • Right to data portability - you can request a copy of your Personal Data. We can provide this copy to third parties at your request.
  • Right of objection - you can object to the processing of your Personal Data.
  • Right to object - you can file a complaint at the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you are of the opinion that we wrongfully process your Personal Data.
  • Right to withdraw consent - you can always revoke your consent to the processing of your Personal Data, by withdrawing your consent to the relevant functionality (such as disconnecting a Tracker). From the moment of your withdrawal, we can no longer provide that Service and we won’t process the related Personal Data anymore.

SECTION 8 - Cookies

A cookie is a small text file that can be sent via the server of a website to the browser. The browser saves this file to your computer. Your computer is tagged with a unique number, which enables our site to recognize that computer in the future.

We use cookies to improve the user experience on our Website. Moreover, cookies ensure that our Website and App work faster, that you can visit our Website and App safely and that we can track and solve errors on our Website and App.

You can always delete or disable cookies yourself via the browser settings. No more cookies will be stored when you visit our Website or App. However, please note that without cookies, our Website and App may not function as well as it should.

Questions?

If you have have any questions, you can consult the Knowledge Base on our Website or read our Terms and Conditions for more information. In the event of questions or remarks regarding privacy, you can contact our DPO at the following e-mail address: [email protected].